Are there any regulations or guidelines for reducing the hours a branch can stay open?
I am trying to obtain a good definition and/or guidance on how to report Revolving Lines of Credit that have been extended and not renewed for a particular year. Example – A customer has a revolving line of credit for $250,000 that originally was executed in November 2014 and is up for renewal in November 2015, however the borrower has asked for a 3-month extension which the bank granted, the amount and conditions are unchanged.
For 2015 reporting, can we/should we be reporting/treating the $250,000 as a renewal/extension that took place in 2015? Or not report it as it was an extension and not a renewal according to the CRA quidelines?
The CRA regulation states, "generally, an institution is to rely on the revenues that it considered in making its credit decision." It also states, "The regulation does not require institutions to request or consider revenue information when making a loan; however, if institutions do gather this information from their borrowers, the agencies expect them to collect and rely upon the borrowers' gross revenue for purposes of CRA."
Does one of these trump the other? We use personal income for the credit decision and rarely use gross revenues of the business. Our auditors think the "credit decision" amounts outweigh using what we have in the file. If we only used the credit decision amounts, we wouldn't have many loans to report.
What documentation would you suggest to prove a community development loan with the purpose of revitalization/stabilization in a moderate- income area? We are financing the purchase and construction of a mixed use development with upper income housing, retail and commercial space. The housing units have been completed but our loan will finance the finish out of the retail/commercial space. Development has TIF credits that our borrower will receive.